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college expenses. During the years in issue, petitioners reduced
their home mortgage balance from $36,857 to zero and reduced
their home equity loan balance from $47,823 to $20,062. In 1992,
they also spent a total of $32,299 for improvements to their
residence and landscaping.
Mr. Black has a history of refusing to cooperate with
respondent’s agents. During the examination of his taxable years
1979 through 1981, Mr. Black refused to discuss the large
deductions claimed for contributions to the Universal Life
Church. During Agent Helton’s investigation of taxable years
1987 through 1989, Mr. Black generally was unresponsive and
evasive. At trial, while cross-examining Agent Helton, Mr. Black
described his own behavior during that audit as “a little
evasive”.
Finally, during the examination of his taxable years 1991
and 1992, Mr. Black refused to meet first with Agent McCarter and
then with both Agents McCarter and O’Dell. Consequently, all of
Agent McCarter’s and Agent O’Dell’s contacts with Mr. Black were
made through his representatives. Although the Agents attempted
to get Mr. Black to cooperate, he provided only limited records.
Mr. Black failed to provide records for the bank accounts that
were in his name. Mr. Black refused respondent’s repeated
requests to classify his checks as either business or personal
and to provide information concerning petitioners’ cash on hand.
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Last modified: March 27, 2008